The country of origin of LED light bars
Issued July 17, 2025 by U.S. Customs and Border Protection.
Tariff classification
Product description
The merchandise is three models of LED lights identified as the Rechargeable Motion Sensing Light Bars, Jasco Models 80876, 84409 and 84410.
CBP rationale
substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). We find that, although the overwhelming majority of components and materials are imported (of non-Thai origin), the PBCAs (light source) are fabricated in Thailand. They are the most important or critical components in the subject LED light bars, which also impart the character of the LED light bars. The SMT process to create the light source along with other assembly operations performed in Thailand are complex and meaningful, thus, the substantial transformation has occurred. As such, we are of the view that country of origin of the LED light bars is Thailand for purposes of current trade remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.
Full text
N350883
July 17, 2025
OT:RR:NC:N4:410
CATEGORY: Origin Christopher LaVenture Jasco Product Company 10 E Memroial Road Oklahoma City, OK 73114 RE: The country of origin of LED light bars Dear Mr. LaVenture: In your letter dated July 2, 2025, you requested a country of origin ruling on LED light bars for purposes of current trade remedies. The merchandise is three models of LED lights identified as the Rechargeable Motion Sensing Light Bars, Jasco Models 80876, 84409 and 84410. You state that all models have the same construction but different in length. Each of the lights consists of the following components and materials: Aluminum enclosure Top plastic end cap Bottom plastic end cap On/Off button Dimmer button Lampshade Light guide panel Reflective sheet Magnet Glue Electronic yellow glue Double tape Leadwire Main PCB (Printed Circuit Board) Lamp PCB Battery LEDs Metal sheet w/ 3M tape
Mainboard set screws End cap set screws Cable All of these components are of Chinese-origin, except for the LEDs, mainboard set screws, end cap set screws, and cable, which are made in Thailand. The Chinese-origin components and materials are shipped to Thailand where they are combined with the Thai-made components to fabricate the finished LED lights. The assembly process in Thailand begins with the production of the PCBAs, in which, the Chinese origin-PCBs are populated with the Thai-origin LEDs via the SMT (Surface Mount Technology) process to produce the light source. The assembly operations following the SMT include 17 steps to assemble the components into a finished light involving screwing, soldiering, taping, inspection and testing. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). We find that, although the overwhelming majority of components and materials are imported (of non-Thai origin), the PBCAs (light source) are fabricated in Thailand. They are the most important or critical components in the subject LED light bars, which also impart the character of the LED light bars. The SMT process to create the light source along with other assembly operations performed in Thailand are complex and meaningful, thus, the substantial transformation has occurred. As such, we are of the view that country of origin of the LED light bars is Thailand for purposes of current trade remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Michael Chen at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division
Ruling history
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